Mother Dairy Fruit & Vegetable Private Limited

• Mother Dairy makes a clear commitment to grow commercially with a focus on nutrition. Its strategy involves fortifying relevant milk products and edible oils with Vitamins A and D, while emphasizing the affordability of its milk portfolio. Meanwhile it invests in R&D to develop new products to meet the nutritional needs of its consumers, reporting that it launched eight of such products in FY 2021-22 (although it does not specify which).

Aspects to improve • Mother Dairy is encouraged to publish its nutrition strategy in a more detailed and cohesive form, laying out how the company plans to improve the healthiness of its product portfolio and increase sales of its ‘healthier’ and fortified products, including through affordable pricing and marketing. As a foundation for this, it is important that the company develops a clear definition of ‘healthier’, according to clear nutrition criteria (ideally, through the use of a nutrient profiling model (NPM)).
• To drive progress internally on implementing its nutrition strategy, the company is recommended to develop specific, measurable, and timebound targets encompassing various elements of its approach, and an overall target to increase sales of the products it defines as ‘healthier’.
• To demonstrate to external stakeholders that it is delivering on its nutrition strategy and/or commitments, Mother Dairy is recommended to report more comprehensively on all elements of its approach, showing what has been achieved year-on-year across its portfolio or key product categories. Reporting should ideally take the form of quantitative metrics, rather than specific examples only, and progress documented systematically.  
• Mother Dairy is encouraged to publish information clarifying the internal governance arrangements for its nutrition approach, for example whether it is subject to regular review at Board-level, and which person is accountable for its implementation and success. It is recommended to assign formal responsibility for the success of its nutrition strategy to the highest levels of seniority within the company. 
• In developing its nutrition strategy and approach, and to ensure that it is maximizing its positive impact on public health, the company is strongly recommended to engage with independent experts/stakeholders, such as independent (i.e. not directly affiliated with industry) public health-oriented civil society organizations, academic institutions, (inter-)national organizations.

Category B2: Portfolio Development

• Mother Dairy continues to voluntarily fortify all relevant products (edible oil and milk) according to the Food Safety and Standards Authority of India (FSSAI)’s Food Safety and Standards (Fortification of Foods) Regulation. This is best practice and illustrates the company’s commitment to tackle Vitamin A and D deficiencies in India.
• The company has expanded its fortified food category to include fortified baked goods such as bread enriched with Vitamin B12, Zinc, and Folic Acid.
• In 2018, the company made commitments to the FSSAI Eat Right Pledge and has since disclosed its achievement in meeting the targets for sugar reduction of 30% in its yoghurts category. However, no new reformulation targets have been set.

Category B3: Nutrient Profiling

• The company did not provide evidence that it uses a nutrient profile model (NPM) or other objective nutrition criteria to evaluate the nutritional quality of its products to inform new product development, product reformulation, or defining ‘healthier’ products.

Aspects to improve Category B2: Portfolio Development

• In order to drive progress on improving the healthiness of its portfolio and build further on its 2018 Eat Right Pledge, the company is encouraged to set new targets to reduce nutrients of concern (sodium, sugar, and saturated fat) and increase positive ingredients (including whole grains and FVNL) across its relevant portfolio; these should be specific, measurable, and timebound. These targets should ideally be aligned with the ICMR/NIN Dietary Guidelines and RDAs for Indians, and/or WHO guidelines, and are recommended to be published on the public domain.
• The company is recommended to report progress against all reformulation targets on an annual basis, in a consistent and easily accessible manner, in order to increase transparency and accountability.
• The company is strongly encouraged to develop an internal policy to prevent the fortification or enrichment of unhealthy products (i.e. with high levels of fat, sugar, and/or sodium), for example, according to nutrition criteria defined by an (internationally recognized) NPM. Thereafter, it is encouraged to produce more fortified products to address specific micronutrient deficiencies in India according to government priorities, while ensuring that these are ‘healthier’.

Category B3: Nutrient Profiling

• The company is strongly encouraged to adopt a nutrient profiling model (NPM) to determine the relative healthiness of all products in its portfolio.  
• Ideally, this should be (or align closely with) an internationally recognized (or, when applicable, government-endorsed) NPM; if developing its own, the company is encouraged to apply stringent thresholds for nutrients of concern that align with (inter)national standards, and use per 100g as the reference unit (to ensure greater objectivity and comparability). 
• The company is recommended to disclose all details of the NPM it uses in full, including the algorithm used to define ‘healthy’, on the company’s India website and, ideally, in a scientific journal that is peer-reviewed and indexed.

• The company's website states that its mission is to “Provide quality food and beverages to consumers at affordable prices while ensuring fair returns to the producers”, indicating a commitment to affordability.
• The company also empha sizes that it did not increase the price of its milk products after it began to fortify them with Vitamins A and D, sharing that these products tend to be in the range of Rs. 10-20 rupees for 200-300 ml volumes.
• However, beyond this it was not clear how the company ensures that its healthier products are priced affordably for lower-income consumers in India.

Aspects to improve • To ensure that products that are considered by the company to be ‘healthier’ are being priced affordably for lower-income consumers, the company is recommended to:   
— ensure that such products are defined as ‘healthy’ through the use of a nutrient profiling model (NPM) (or other clear nutrition criteria) - such that products high in fat, salt and sugar (HFSS) are specifically excluded;  
— have a clear approach to determining whether a product is ‘affordably priced’; and  
— use a formal classification of ‘lower-income consumers’ that it is trying to reach.  
• With these definitions and processes in place, the company is encouraged to develop and implement a strategy or approach for ensuring that at least part of its ‘healthier’ (and, ideally, fortified or micronutrient-rich) product portfolio is priced affordably for lower-income consumers, and continually explore new opportunities for delivering ‘affordable nutrition’. Examples of approaches can be found in the methodology and chapter for Category C.  
• The company is recommended to publicly disclose information about its affordable nutrition strategies/approaches, including specific definitions, the approaches taken to ensure affordability, and the progress made on implementation.

• No policy or commitments for responsible marketing to children and/or general audiences was shared with ATNI that go beyond legal requirements in India.

Aspects to improve • The company is encouraged to develop and publish a comprehensive responsible marketing policy that covers all media channels and audiences, including children under the age of 18 (in line with CCPA guidelines).
• The company is encouraged to ensure more responsible marketing to children by adopting:
— an audience threshold of 25% for limiting children’s exposure to advertisements on all media;
— specific commitments not to use certain materials and techniques to market their products to children, including celebrities, licensed characters, promotional toys and games, and depicting children on packaging.
• The company is encouraged to commission regular third-party audits of compliance to its responsible marketing policy in India, and to disclose the results of this audit, as well as the response mechanism it has in place to address instances of non-compliance.

• The company has a workforce nutrition initiative in place called 'Sahi Poshan Swasth Jeevan’ as part of the ‘Safe and Nutritious Food' (SNF) at Workplace Initiative by Food Safety and Standards Authority of India (FSSAI). It has three pillars: ‘Aware', 'Engage', and 'Nourish', although it is not clear what is in place specifically for the company.
• The company does not offer paid paternity leave to its employees.
• It is not clear whether or how the company supports breastfeeding mothers in its workforce.

Aspects to improve • The company is recommended to disclose more details about its workforce nutrition program, and ensure that it includes providing access to healthy food at work, nutrition education, nutrition-related health checks, and breastfeeding support. This program should ideally be available to all employees, including those at manufacturing sites.
• The company is recommended to define quantifiable and meaningful expected outcomes for its workforce nutrition program and evaluate it accordingly - for example related to health-related behaviors, health-related outcomes, outcomes related to employee participation, or benefits to the company. Becoming a signatory of the Workforce Nutrition Alliance and utilizing its self-assessment scorecards could be a good first step in this regard.
• The company is encouraged to develop a clear policy on support extended to breastfeeding mothers at work in order to aid their maternal health; and this should apply equally to all office and production site employees. Support should, at a minimum, include i) Private, hygienic, safe rooms for expressing breastmilk; ii) Refrigerators in place to store milk; and iii) Other flexible working arrangements to support breastfeeding mothers, such as flexible working hours or on-site creche facilities. Furthermore, it is important to foster a workplace culture that is supportive of breastfeeding, for example through awareness campaigns.
• The company is recommended to offer maternity and paternity or second caregiver leave, extending parental leave policies to go beyond current national regulations, and remove limitations based on the number of children born.
• The company is also encouraged to develop a workforce nutrition program for its supply chain workers in India, starting with a needs assessment to identify those groups at highest risk of experiencing malnutrition.

• No evidence of a standardized policy or approach to front-of-pack (FOP) product labelling beyond legal requirements could be found on the company’s public domain.
• Images shown for products on its website do not have nutritional information clearly visible, and product pages do not include any additional nutritional information in tables. For some milk products it does indicate the minimum fat and Solid-Not-Fat (SNF) content as a percentage.

Aspects to improve • Once it is formally enacted by FSSAI, if the INR FOP labeling system is on a voluntary basis, the company is strongly encouraged to adopt it across their entire portfolios in India.
• The company is encouraged to ensure that nutritional information is available for all products on its website both as high-definition images of the front and back of products, and as accompanying tables showing comprehensive product-specific nutritional information.

• The company confirmed to ATNI that it is a member of several trade associations in India; however, these are not disclosed on the company’s public domain.
• No other relevant information was found for the company regarding its advocacy policies, processes, positions, or activities in India.

Aspects to improve • The company is encouraged adopt a responsible advocacy policy, which also applies to third-parties advocating on behalf of the company, in which it clearly defines ‘advocacy’ and commits that personnel will conduct themselves responsibly; to be transparent about their identity and intentions; to require that the evidence presented shall be as independent and representative as possible; and to always consider the wider public health interest in its efforts.
• To improve its control over and accountability for its advocacy activities (which includes participation in policy-related multistakeholder meetings, responding to public consultations, and other interactions with policymakers), the company is recommended to ensure that only approved personnel engage with policymakers on nutrition-related policy matters, and ensure that these interactions are tracked and disclosed on the public domain.
• Even if the company is not engaging in a policy debate or development process directly, its trade associations are likely to be, and potentially other third-parties acting on the company’s behalf. Therefore, the company’s policy positions are still important, since it should be engaging with these third-parties to ensure that its positions are taken into account. The company is encouraged to disclose its policy positions on key nutrition-related policy measures under debate or development in India that would likely affect the company (for example, FSSAI’s new FOP labelling system). These positions should be as specific and unambiguous as possible, be Board-approved, and should consider the wider public health interest and long-term material implications of rising levels of malnutrition in India.
• The company is encouraged to disclose comprehensive lists of its trade association memberships in India and clearly indicate which it holds leadership positions on, such as on their Boards, management committees, or thematic working groups or sub-committees, in order to signify to stakeholders which ones the company has greater stakes in. If no such positions are held, this can be publicly stated.